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"42 Section: 9.15 Leather Tanning

Title: Comments and correspondence for the June 1997 supplement

38 Likeview Road Asheville, NC 28804

phone: 704-252-8254 Frank H. Rutland fax:: 704-252-8255

Enuiroiimentnl Cmsul f ing Semices modem: 704-252-8256 e-mail: fhrutland@aol.com for flie katlwr Industnl

April 16, 1997

Mr. Dallas W. Safriet U. S. Environmental Protection Agency Emission Factor and Inventory Group (MD-14) Research Triangle Park, NC 2771 1

RE: Emission Factor Documentation for AP-42, Section 9.15, Leather Tanning

Dear Mr. Safriet:

This is in response to your letter of April 9, 1997 and the enclosed draft version ofAP-42, Section 9.Z5, Leather Tanning. On behalf of Leather Industries of America, we very much appreciate this opportunity to review and comment on this draft. Our comments are summarized briefly below. If we can be of further assistance in preparation of the final report, please do not hesitate to contact me.

1. Page 2-1. paragraph 2. last sentence - substitute “are umally’; for “must be. ” It is normal, but not essential to perform addition operations after chrome tanning.

2. Page 2-1. paragraph 3. first sentence - the 120 leather tanning and finishing facilities mentioned and shown on the map in Figure 2-1 include a number of importingharketing firms that have no manufacturing operations at all. California, for example, has only one tanning facility - the others represent sales offices only. If desirable, I will be happy to work with you to establish a more accurate list.

3. Page 2-3. paragraph 2. 2nd sentence - delete “or dried.” Hides or skins that have been allowed to dry out are very difficult to rewet, and thus have limited utility for tanning.

4. Pave 2-3. paragraph 2. next to last sentence - delete “and the soak water that contains salt, solubleproteins, impurities, and bacteria. ” This has no relevance to the fleshing operation.

5. Page 2-3. paragraph 4. first sentence - delete “and alters the welling characteristics of the skin. ” The liming process does cause swelling of the hide (“expands the dermal fiber network”), but it does not in any way alter the swelling characteristics of the skin.

6. Page 2-4. Firmre 2-2:

Most cattlehide siding is now done in conjunction with wringing rather than initial trimming.

Delete the “Retan (Optiotial) ” after “Chrome Tan. ” Retanning of chrome tanned and some vegetable tanned leathers is done after Shaving and before Coloring, as shown.

Leather dyeing (“Bleaching and Coloring”) is an aqueous operation and is not a source of VOC emissions.

Leather drying, including vacuum drying, is not a source of particulate emissions

7. Pape 2-5. paragraph 2. 3rd sentence - substitute “glohular proleitis” for “protein degraahtion products. ”

8. Pape 2-5, paramaoh 3.2nd sentence - “to a@st the acidity andpH” is redundant. Therefore, either one or the other should be deleted.

9. PaPe 2-6. oaragraoh 3. first sentence - add “has higher thermal slability” after “than vegeiahle- tanned leather. ”

10. Page 2-6. paragraph 3. last sentence - substitute “may” for “must” (see above).

I I . Page 2-6. paragraph 4. 3rd sentence - this sentence should be deleted entirely. Chrome tanning is done exclusively with trivalent chromium, usually in the form of basic chromic sulfate. Virtually all U.S. tanneries buy pre-reduced basic chromic sulfate either in solution or powder form - not sodium dichromate. Currently, only two U.S. tanneries produce their own chromic sulfate solution from sodium dichromate.

12. Pape 2-6. last oaragraoh - this paragraph should be entirely deleted. The two-bath process is no longer used in this country.

13. Page 2-6. paramaoh 2,4th sentence - insert “(known as splits) “ after “jlesh layers. ”

14. Pape 2-7. DaraPraoh 3. first sentence - change to read “Leather that is not suhject to scufls and scraiches may he dyed on the surface oniy. For other types of leather, however, ihe dye must----. .,

15. Page 2-7. paragraph 4. last sentence - substitute “drying” for ‘Yatliiyuoring. ”

16. PaPe 2-7. last paragraph - there are now five methods of drying in common use. The fifth is high frequency drying, which uses a high frequency electromagnetic field similar to the kitchen microwave.

17. Page 2-8. paragraph 1. 3rd sentence (beginnine. “Paste drvinn is used--. ’’1 - I would be inclined to delete this sentence entirely. Paste drying can be used for all types of leather, not just the ones listed, and is not significantly more expensive than other types of drying, with the exception of air drying.

18. Page 2-8. Section 2.2.3 - I have great difficulty with this entire section. It serves little if any purpose and should be deleted along with Figure 2-3. As indicated below, much of the information in this section is inaccurate or outdated.

There is almost no production of small skin garment suede in the United States today, and only a handful of small skin tanneries remaining.

The majority of suede leather produced in this country comes from cattlehide splits, rather than sheep skins, and goes into footwear plus some heavier weight garment suede.

Solvent degreasing is virtually a thing of the past and, to the best of my knowledge, is currently used at only one facility for the production of chamois leather.

Finally, having a separate section on suede leather conveys the impression that suede production is in some way fundamentally different from an emission standpoint. This is misleading. The flow diagram in Figure 2-2 is completely adequate to cover production of virtually all types of both grain and suede leather.

19. Page 2-10. paragraph 1. 3rd sentence - this sentence should be entirely deleted since solvent degreasing is rarely if ever used today.

20. Page 2- IO. paragraph 1. last sentence - delete “that occur at elevated temperatures. ”

21. Page 2-10. paragraph 2. 2nd sentence - substitute “chemical/y removed from” for “burned ofs ”

22. Page 2-10. paragraph 2. last sentence - delete “vacuum drying. ”

23. Pave 2-10. paragraph 3. first sentence - this sentence should be changed to read “Chromium emissions may occur from chromate reduction, handling of basic chromic surfate powder and from the birffg process. ”

24. Page 2-10. paragraph 3. 3rd sentence - this sentence should be changed to read “A/ plants which purchase chromic sulfate in powder form, dust cotrtaining trivalenf chromium may be emitfed I ,

25. Page 2-10. paragraph 4. 2nd sentence - to the best of our knowledge, there is only one facility in the industry using incineration for control of VOC emissions.

26. Section 9.15.1, paragraph 3. first sentence - see comment No. 2 above.

27. Section 9.15.2. 3rd sentence - delete “und suede leafher production. ” See comment No. 18 above.

28. Figure 9.15-1 - see comment No. 6 above.

29. Section 9.15.2.1, paraEraph 1. 3rd sentence - delete “and the soak water. ” See comment No. 4 above.

30. Section 9.15.2.1. paragraph 1, last sentence - see comment No. 8 above

31. Section 9.15.2.1. paragraph 3. first sentence - see comment No. 16 above

32. Section 9.15.2.2, paragraph 1. first sentence - see comment No. 9 above.

33. Section 9.15.2.2. paragraph I , last sentence - see comment No. 10 above

34. Section 9.15.2.2. paragraph 2, first sentence - delete “ulmost enfire& ” See comment No. 12 above.

35. Section 9.15.2.2. paragraph 2, 5th and 6th sentences - see comment No. 14 above.

36. Section 9.15.2.2. paragraph 3. last sentence - see comment No. 15 above

37. Section 9.15.2.3 and Figure 9.15-2 - delete entirely. See comment No. 18 above.

38. Section 9.15.3. paragraph 1. 3rd sentence - delete entirely. See comment No. 18 regarding solvent degreasing.

39. Section 9.15.3. paragraph 1. 4th sentence - see comment No. 25 above

40. Section 9.15.3. paragraph 1, last sentence - delete “vuczmm &ying. ” See comment No 6 regarding vacuum drying above.

41. Section 9.15.3. paragraph 2. 3rd sentence - see comment No. 24 above.

General Comments:

Chrome tanning now accounts for 90+% of total U. S. tannery production, with vegetable tanning making up most of the remainder. In addition, a high percentage of vegetable tanned leathers are sold without retanning, coloring, fatliquoring or finishing. Neither of these facts is apparent from the way in which this report is organized.

EPA has totally failed to provide guidance to those industries that purchase chemical raw materials which may be volatile when received, using EPA Method 24, but because of chemical polymerization or other bonding mechanisms are rendered non- volatile in the finished product, and thus should not be considered as potential sources of VOC emissions. The draft report is totally silent on this issue.

The overall description of the leather tanning process provided in this draft report is extremely general and simplistic - so much so it would appear to be of questionable utility. There are very significant differences between individual industry facilities, based on type of raw material used (e.g. cattlehides, pig skins, sheep skins, goat skins,

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deer skins, horse hides, exotic skins, etc.), processing technology, raw material chemicals and types of leather produced (e.g. footwear. upholstery, garment, personal leather goods, athletic, equestrian, etc.). It is very difficult to encompass all of these variations in one simplified process description. In light of this, and the fact no emission factors have been developed due to the lack of source test data (Section 4.3), one is forced to wonder exactly what purpose this draft report is expected to serve.

Again, we would like to express our appreciation for this opportunity to comment on the AP-42, Section 9.15 draft report. We sincerely hope these comments will be carehlly considered and incorporated into the final version of this report. Please do not hesitate to contact me if there are hrther questions on any of the points raised above.

Very sincerely, LEATHER INDUSTRIES OF AMERICA, INC.

J

Environmental Consultant

EQP 5700

AIR QUALITY DIVISION MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY ’ PO BOX 30260 LANSING MI 48909-7760

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.,A SUPPLEMENT TO PERMIT NO. 1 189-90A

Eagle Ottawa Leather Compcny Grand Haven. Michigan

August 1 ~ 1995

GENERAL CONCITIONS

I . 2ule 208(2) - Not more thcn 30 days after completion of the installation, Applicant shall apply, in writing, for c Permit to Operate. Completion of the installaiion is deemed to occur not later than commencement of a Triol operation pursuant ?a Rule 201 (4). Written application should be sent to: Supervisor, Permit Secticn. Air Quality Division, Depaemeni of Natural Resources, P.O. Box 30260, Lcnsing. Michigan 48909.

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Rule 201(4) - Trial operation of the equipment is permitted tintil the Michigan Department of Natural Resources, nereina%er"Depa~meni", ccts upon ihe Permit to Operate. Operation of the equipment shall permanently cease upon denial of the Permit to Operate by the Cepartment.

Rule 208(3)(c) cnd (c) - Applicant shcll demonsirate compliance with all Deportment rules and with cll general and special conditions of this permit prior to issuance of the Permit io Operate.

Rule 201 - Applicant shcll not reconstruc?, alter, modify, expand. or relocste this equipment unless plans, speciiicdions, and an application for a ?emit io insiall are submitted to and approved by ihe Deparrment.

Rule 901 - Operation of :his equipment shall not result in the imissicn of an air contcminant which causes injurious affects to human health or safety, animal life, plant life of significant value, or property, or which cacises unreasonable interference with the comfortable enjoyment of life and property.

Rule 208(3)(b) - Operation of this equipment shall not interfere with the attainment or maintenance of the air quality sfandard far any air contaminant.

Operation of this equipment shall not result in significant deteriorctian of air quality.

Rule 912 - Appliccnt shall provide notification of any abnormal conditions or malfunction of process or control equipment covered by this application. resulting in emissions in violation of ihe Depcrtment rules or of any permit conditions for more than two hours, to the Cistrict Supervisor. Such notice shall be made as soon as reasonably possible, but not later than 9:OO a.m. of the next working day. Applicant shall also, within 10 days, submit to the District Supervisor, a written detailed report, including probable causes. duration of violation. remedial action taken, and the steps which are being undertaken io prevent a reoccurrence.

Approval of this application does not exempt the Applicant from complying with any future regulations which may be promulgated under Ac t 451, P.A. 1994, c s amended.

Approval of this permit does not obviate the necessity of obtoining such permits or approvals from other units of government cs required by law.

Eagle Ottawa Leather Company Permit No. 1 189-90A Page 2 August 1, 1995

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Act No. 53 - Applicant shall notify any public utility of any excavation, tunneling and discharging of explosives or demolition of buildings which may affect said utility's facilities in accordance with Act 53 of the Public Acts of 1974, being sections 460.701 to 460.718 of the Michigan Compiled Laws and comply with each of the requirements of that Act.

The restrictions and conditions of this Permit to lnstall shall apply to any penon or legal entity which now or shall hereafter own or operate the equipment for which this Permit to Install is issued. Any new owner or operator shall immediately notify the Supervisor of the Permit Section, in writing, of such change in ownership or principal operator status of this equipment.

Rule 201 (5) - If the installation, reconstruction. relocation, or alteration of the equipment for which this permit has been approved has not commenced within, or has been interrupted for, 18 months, this permit shall become void unless otherwise authorized by the Department.

Rule 285 - Except as allowed by Rule 285 (a), (b], and (c), applicant shall not substitute any fuels, coatings, nor raw materials for those described in the application and allowed by this permit, nor make changes to the process or process equipment described in the application, without prior notification to and approval by the Air Quclity Division.

SPECIAL CONDITIONS

The volatile organic compound (VOC) emission rate from the Double Poletto No. 2 finishing machine, hereinafter "process", shall not exceed 43.6 pounds per hour nor 99.9 tons per year based on a 12-month rolling average as determined at the end of each calendar month.

The applicant shall not use any coating in the process that will exceed 3.10 pounds of VOC per gallon, minus water and exempt solvents. as applied.

The VOC emission rate from the process shall not exceed 0.15 pound per whole hide, based upon a monthly averaging period.

Rules 1001, 1003 and 1004 - Verification of VOC and particulate emission rates from the process by testing, at owner's expense, in accordance with Department requirements, may be required for operating approval. Verification of emission rates includes the submittal of a complete report of the test results. If a test is required, stack testing procedures and the location of stack testing ports must have prior approval by the District Supervisor, Air Quality Division, and results shall be submitted within 120 days of the written requirement for such verification.

The VOC content of any coating as applied shall be determined using federal Reference Test Method 24. Upon prior approval of the District Supervisor, Air Quality

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/ ' 1 - 1

&gle Ottawa Leather Company 'I ' Permit NO. I 189-90A

/ August 1, 1??5 Pcge3

Division, VOC content of any coating may alternatively be determined from / /

I mcnufacturets formulation data.

20. Appliccnt shall keep a separate record of the following for the process:

A. Tcr each coating applied on a daily basis:

1 . The identification and the coating category for each coating used. 2. The VOC content in pounds per gallon of coating (minus wcter) as

received and as applied. 3. The VOC content in pounds per gallon of reducers and

catalysts. 4. The amount in gallons of coating as applied.

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C.

The daily number of hides coated.

VOC Ernission calculctjons determining the monthly VOC emission rcte in tcns per month and the I lmonth rolling average emission rate in tons per year.

The calculated average monthly 'JOC emission rate in pounds of VOC per whole hide.

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This information shall be kept on file for a period of at least two yeors and made available to the Air Quality Division upon request.

21. A report demonstrating compliance with the applicable VOC emission limits specified in Special Condition Nos. 15. 16, and 17 shall be prepared in an acceptable format within 30 days following the end of the quarter in which the data were collected. This information shall be kept on file for a period of at least two years and made available to the Air Quality Division upon request.

There shall be no visible emissions from the process stacks and the associated building housing the process equipment.

Applicant shall not operate the process unless the water wash is installed and

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23. . operating properly.

24. Applicant shall not operate the process unless the optic eye spray gun controllers are installed and operating properly.

The disposal of collected solvents and coatings shall be performed in a manner which minimizes the introduction of air contaminants to the outer air.

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Eagle Ottawa Leather Compcny Permit No. 1 189-90A Page 4 August 1, 1995

25. The exhaust gases from the processes specified in specicl condition 15 shall be discharged unobstructed vertically upwards to the ambient air from stacks with maximum diameters and exit points above ground level not less than os follows:

Equipment Stack Height Stack Oicmeter (feet] (inches]

Spray booth (3 stacks] 54 Drying Tunnel (2 stacks] 54

36 36

WAP:cmb

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SUPPLEMENT TO ?ERMIT NO. 421-78A

Ecgle Ottawa Leather Company Grand Haven, Michigan

August 1. 1995

GENERAL CONDITIONS

Rule 208(2) - Not more than 30 days after completion of the installation. Applicant shall apply, in writing, for a Permit to Operate. Complerion of the installation is deemed to occur not later than commencement of a tricl operation pursuant to Rule 201 (4 ) . Written application should be sent io: Supervisor, Permit Section, Air Quality Division, Department of Natural .Resources, P.O. Box 3020G. Lansing, Michigan 48909.

Rule 201(4) - Trial cperction of the equipment is permitted until the Michigcn Department of Natural Resources. hereinafter "DepartmenY', acts upon the Permit to Operate. Operation of ihe equipment shall permanently cease upon denial a i :he Permit to Operate by the Department.

Rule 208(3)(a) and (c) - Applicant shall demonstraie mmpliance with cII Department rules and wiih all genercl and special conditions of ihis permit pricr io issuance of the Permit to Operaie.

Rule 201 - Applicant shcll not reconstruct, alter, mcdiiy, exsand. or reiccate this equipment unless plans. specifications, and an apFiication for a Permit to Install crs submitted :o and cpproved by the Depariment.

Rule 901 - Operation of this equipment shall not result in the emission of an air contarnincnt which causes injurious effecfs to humcn health or safety, animal life, plant life of significant value, or properly, or which ccIuses unreasonable interference with the comfortable enjoyment of life and properly.

Rule 208(3)(b) - Operation of this equipment shall not interfere with the attainment or maintenance of the air qualify standcrd for any cir codominant.

Operation of this equipment shall not result in significant deterioration of air quality.

Rule 912 - Applicant shall provide notification of any abnormal conditions or malfunction of process or control equipment covered by this application, resulting in'&missions in violation of the Department rules or of any permit ccnditions for mcre than two hours, to the District Supervisor. Such notice shall be made as soon as reasonably possible, but not later than 9:OO a.m. of the next working day. Applicant shall also, within 10 days, submit to the District Supervisor, a written detailed report, including probable causes, duration of violation. remedial action token. and the steps which are being undertaken to prevent a reoccurrence.

Eagle Ottawa Leather Company Permit No. 42 1 -78A Page 2 August I , 1995

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Approval of this application does not exempt the Applicant from complying with any future regulations which may be promulgated under A c t 451, P.A. 1994, as amended.

Approval of this permit does not obviate the necessity of obtaining such permits or approvals from other units of government as required by law.

A c t No. 53 - Applicant shall notify any public utility of any excavation, tunneling and discharging of explosives or demolition of buildings which may affect said utility’s facilities in accordance with Act 53 of !he Public Acts of 1974, being sections 460.701 to 460.718 of the Michigan Compiled Laws and comply with each of the requirements of that Act.

The restrictions and conditions of this Permit to Install shall apply to any person or legal entity which now or shall hereafter own or operate the equipment for which this Permit to Install is issued. Any new owner or operator shall immediately notify the Supervisor of the Permit Section. in writing, of such change in ownership or principal operator status of this equipment.

Rule 201(5) - If the installation, reconstruction, relocation, or alteration of the equipment for which this permit has been approved has not commenced within, or has been interrupted for, 18 months, this permit shall become void unless otherwise authol‘zed by the Depcriment.

Rule 285 - Except as allowed by Rule 285 (a). (b). and (c), applicant shall not substitute any fuels, coatings, nor raw materials for those described in the application and allowed by this permit, nor make changes to the proc, oss or process equipment described in the application, without prior notification to and approval by the Air Quality Division.

SPECIAL CONDITIONS

The volatile organic compound (VOC) emission rate from the Rimi leather finishing machine, hereinafter “process”, shall not exceed 11.2 pounds per hour nor 25.0 tons per year based on a 12-month rolling average as determined at the end of each calendar month.

The applicant shall not use any coating in the process that will exceed 3.10 pounds of VOC per gallon, minus water and exempt solvents, as applied.

The VOC emission rate from the process shall not exceed 0.15 pound per whole hide, based upon a monthly averaging period.

Rules 1001, 1003 and 1004 - Verification of VOC and particulate emission rates from the process by testing, at ownets expense, in accordance with Department requirements, may be required for operating approval. Verification of emission rates includes the submittal of a complete report of the test results. If a test is

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Eagle Ottawa Leather Company Permit No. 42 1 -78A Page 3 August 1 , 1995

required. stack testing procedures ond the location of stock testing ports ,must hove prior approval by the District Supervisor, Air Quality Division, and results shall be submitted within 120 days of the written requirement for such verification.

The VOC content of cny coating os applied sholl be determined using federal Reference Test Method 24. Upon prior approval of the Disirict Supervisor, Air Quality Division, VOC content cf any coating moy alternatively be determined from manufacturer's iormulaticn data.

Applicant shall keep a separote record of the following for the process:

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For each coating applied on a daily bcsis:

1 . The identification and the coating category for each coating used. 2. The VOC cmient in pounds per gallon of coating (minus water) os

received cnd cs applied. 3. The VOC conrent in pounds per gallon of reducers and

cctalysts. 4. The amount in Gallons of coatins as applied.

The daily number ci hides cooted.

VOC Emission calcuiations determining the monthly VOC emission rcte in tons per month ond the i2-month rolling average emission rate in tons per year.

The calculated cverage monthly VOC emission rate in pounds of VOC per whole hide.

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C.

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This information shall be kept on file for a period of at least two years and made available to the Air Quality Division upon request.

21. A report demonstrating compliance with the applicable VOC emission limits specified in Special Condition Nos. 15. 16, and 17 sholl be prepared in an acceptable format within 30 days following the end of the quarter in which the data were collected. This information shall be kept on file for a period of at least two yeon ond made available to the Air Quality Division upon request.

There shall be no visible emissions from the process stacks and the associated building housing the process equipment..

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23. Applicant shall not operate the process unless the water wash is installed and operating properly.

The disposal of co1lec;ed solvents and coatings shall be performed in o manner which minimizes the iniroduction of oir contaminants to the outer cir.

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Eagle Ottawa Leather Company Permit No. 421 -78A Page 4 August 1, 1995

25. The exhaust gases from the processes specified in special condition 15 shall be discharged unobstructed vertically upwards to the ambient air from stacks with maximum diameten and exit points above ground level not less than as follows:

Equipment Stack Height Stack Diameter (feet) (inches)

Spray 800th 50 Drying Tunnel ( 1 ) 38

(2) 37

WAP:cmb

42 24 16

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h, i ., SUPPLEMENT TO PERMIT NO. 459-89A

Eagle Ottawa Leather Company Grand Haven, Michigan

August 1, 1995

GENERAL CONDITIONS

1. Rule 208(2) - Not more thcn 30 days after completion of the installation, Applicant shall apply, in writing, for a Permit to Opercte. Completion of the installaticn is deemed to occur not later than ccmmencement of a trial operotion pursuant to Rule 201 (4). Written application should be sent to: Supervisor, Permit Section, Air Quality Division, Depcriment of Naturcl Resources, P.O. Box 30260, Lansing, Michigan 48909.

Rule 201(4) - Trial operation of the equipment is permitted until the Michigan Department of Natural Resources, hereinafter "Department", acts upon the Permit to Operate. Operation of the equipment sholl permanently cease upon denial of the Permit to Opercte by the Department.

3. Rule 208(3)(0) and (c) - Applicant shall demonstrate compliance with all Department rules and with all generci and special conditions of this permit pricr to issuance of the Permit to Operate.

Rule 201 - Applicant sholl not reconstruct, alter, modiw, expand, 3r relocate this equipment unless plcns, specificctions, and an application for o Permit to lnstcll cre submittec io cnd approved by the Depcrtment.

Rule 901 - Operaticn of this equipment shall not result in the emission of an cir contaminant which ccuses injurious effects to human health or safety, animal life, plant life of significant value, or properly, or which cmses unreasonable interference with the csmiortable enjoyment of life ond properly.

Rule 208(3)(b) - Operaiion of this equipment shall not interfere with the attainment or maintenance of the air quaiity standard for any air cmtaminant.

Operation of this equipment shall not result in significant deterioration of air quality.

Rule 912 - Applicant shall provide notification of any abnormal conditions or malfunction of process or control equipment covered by this application, resulting in emissions in violation of the Department rules or of any permit conditions for more than two hours, to the District Supervisor. Such notice shall be made as soon as reasonably possible, but not later than 9:OO a.m. of the next working day. Applicant shall also, within 10 days, submit to the District Supervisor, a written detailed report, including probable causes, duration of violation, remedial action taken, and the steps which are being undertaken to prevent a reoccurrence.

Approval of this application does not exempt the Applicant from complying with any future regulations which may be promulgated under Act 451, P.A. 1994, a s amended.

Approval of this permit does not obviate the necessity of obtaining such permits or approvals from other units o i government a s required by law.

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Eagle Ottawa Leather Company Permit No. 459-89A Page 2 August 1, 1995

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A c t No. 53 - Applicant shall notify any public utility of any excavaiion, tunneling and discharging of explosives or demolition of buildings which may affeci said utility's facilities in accordance with A c t 53 of the Public Acts of 1974, being sections 460.701 to 460.718 of the Michigan Compiled Laws and comply with eacn of the requirements of that Act.

The restrictions and conditions of this Permit to Install shall apply to any person or legal entity which now or shall hereafter own or operate the equipment for which this Permit to Install is issued. Any new owner or operator shall immediately notify the Supervisor of the Permit Section, in writing, of such change in ownership or principal operator status of this equipment.

Rule 201 (5) - If the installation, reconstruction, relocation, or alteration of the equipment for which this permit has been approved has not commenced within, or has been interrupted for, 18 months, this permit shall become void unless otherwise authorized by the Department.

Rule 285 - bcept as allowed by Rule 285 (a), (b), cnd (c), applicant shall not substitute any fuels, coatings, nor raw materials for those described in the application and allowed by this permit, nor make changes to the process or process equipment described in the application, without prior notification to and approval by the Air Quality Division.

SPECIAL CONDITIONS

The volatile organic compound (VOC) emission rate from the Double Poletto No. 1 finishing machine, hereinafter "process", shall not exceed 43.6 pounds per hour nor 99.9 tons per year based on a 12-month rolling average as determined at the end of each calendar month.

The appliccnt shall not use any coating in the process that will exceed 3.10 pounds of VOC per gallon, minus water and exempt solvents, as applied.

The VOC emission rate from the process shall not exceed 0.15 pound per whole hide, based upon a monthly averaging period.

Rules 1001, 1003 and 1004 - Verification of VOC and particulate emission rates from the process by testing, at owner's expense, in accordance with Department requirements, may be required for operating approval. Verification of emission rates includes the submittal of a complete report of the test results. If a test is required, stack testing procedures and the location of stack testing ports must have prior approval by the District Supervisor, Air Quality Division, and results shall be submitted within 120 days of the written requirement for such verification.

The VOC content of'any coating as applied shall be determined using federal Reference Test Method 24. Upon prior approval of the District Supervisor, Air Quality

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4 \','? Ecgle Ottawa Lecther Company Permit No. 459-89A Page 3 August I , 1995

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25.

Division, VOC content of cny cociing may clternatively be determined from manufccturer's formulation data.

Applicant shall keep o separate record of the following for the process:

A. For each coating applied on a daily basis:

1. 2.

3.

4.

The identification and the coating category for each coating used. The VOC content in pounds per gallon of coating (minus water) cs received and cs applied. The VOC content in pounds per gallon of reducers and catalysts. The amount in gallons of coating as applied.

6.

C.

The daily number of hides coated.

VOC Emission calculations determining the monthly VOC emission rcte in tons per month cnd :he 12-month rolling overage emission rate in tons per year.

The calculated averase monthly VGC emission rate in pounds of VOC per whole hide.

D.

This information sholl be kept on file for a pericd of ct least two years and mcde available to the Air Quality Division upon request.

A report demonstrating compliance with the cpplicoble VOC emission limits specified in Special Condition Nos. 15. 16, and 17 shall be =repared in an acceptabie format within 30 days following the end of the quarter in which :he data were collected. This information shall be kept on file for a period of at least two years and made available to the Air Quality Division upon request.

There shall be no visible emissions from the process stacks and the associated building housing the process equipmenf.

Applicant shall not operate the process unless the water wash is installed and operating properly.

Applicant shall not operate the process unless the optic eye spray gun controllen are installed and operating properly.

The disposal of collected solvents and coatings shall be performed in a manner which minimizes the introduction of air contaminants to the outer air.

Eagle Ottawa Leather Company Permit No. 459-89A Page 4 August 1, 1995

26. The exhaust gases from the processes specified in special condition IS shall be discharged unobstructed vertically upwards to the ambient air from stacks with maximum diameters and exit points above ground level not less than as follows:

Equipment Stack !-!eight Stack Diameter (feet) (inches)

Spray booths (4) 46 Drying Tunnel (4) 46

36 24

.I .

Eagle Ottawa Leather Company Permit No. 493-95 Page 3 November 14, 1995

SPECIAL CONDmONS

13. The volatile organic compound (VOC) emission rate from the 2 Hampton rotary spraylines, 2 ovens and associated equipment for coating automotive leather, hereinafter “process”, shall not exceed 18.6 pounds per hour nor 61.1 tons per yeor based on a 12-month rolling average as determined at the end of each calendar month.

The applicant shall not use any topcoat in the process that will exceed 2.60 pounds of VOC per gallon, minus water and exempt solvents, as applied.

The applicant shall not use any coating, excluding topcoat, in the process that will exceed 1.30 pounds of VOC per gallon, minus water and exempt solvents, as applied.

The VOC emission rate from the process shall not exceed 0.12 pound per whole hide, based upon a monthly averaging period.

There shall be no visible emissions from the process.

Rules 100 1, 1003 and 1004 - Verification of VOC and particulate emission rates from the process by testing, at ownecs expense, in accordance with Department requirements, may be required for operating approval. Verification of emission rates includes the submittal of a complete report of the test results. If a test is required, stack testing procedures and the location of stack testing ports must have prior approval by the District Supervisor, Air Quality Division, and results shall be submitted within 120 days of the written requirement for such verification.

The VOC content of any coating as applied shall be determined using federal Reference Test Method 24. Upon p‘or approval of the District Supervisor, Air Quality Division, VOC content of any coating may alternatively be determined from manufacfurets formulation data.

14.

15.

16.

17.

18.

19.

20. AGplicant shall keep a separate record of the following for the process:

A. For each coating applied on a daily bask

1. 2.

3. 4.

The daily number of hides coated.

The identification and the coating category for each coating used. The VOC content in pounds per gallon of coating (minus water and exempt solvents) as received and as applied. The VOC content in pounds per gallon of reducers and catalysts. The amount in gallons of coating as applied.

B.

Eagle Ottawa Leather Company Permit NO. 493-95 Page 4 November 14. 1995

C. VOC Emission calculations determining the monthly VOC emission rate in tons per month and the 12-month rolling average emission rate in tons per year.

The calculated average monthly VOC emission rate in pounds of VOC per whole hide.

D.

This information shall be kept on file for a period of at least two yean and made avoiloble to the Air Quality Division upon request.

21. A report demonstrating compliance with the applicable VOC emission limits specified in Special Condition Nos. 13, 14, 15 and 16 shall be prepared in an acceptable format within 30 days following the end of the quarter in which the dato were collected. This information shall be kept on file for a period of at least two yean and made available to the Air Quality Division upon request.

Applicant shall not operate the rotary spraylines unless the wet sctubben are installed and operating praperfy.

Applicant shall not operate the rotary spraylines unless the optic eye spray gun controllen are installed and operating properly.

The disposal of collected particulate. solvents and coatings shall be performed in a manner which minimizes the introduction of air contaminants to the outer air.

The exhaust gases from the processes specified in special condition 13 shall be discharged UnoDsTruciea v&;cG~$ : .pvzx!s ?n the ambient air from stacks with maximum diameters and exit points above ground level not less than as follows:

22.

23.

24.

25.

Stack 1.0. Equipment Stack Height Stack Diameter (feet) (inches)

1 Booth 1 *2 Booth 1 3 Booth 2 4 Booth 2 5 Oven 1

46 46 46 46 46

24 24 24 24 18

MIDWEST RESEARCH INSTITUTE Suite 350 401 Harrison Oaks Blvd. Cary, N.C. 27513 Telephone (91 9) 677-0249 Fax (91 9) 677-0065

FAX TRANSMISSION

TO: DNR

FROM: Amy M. M a l l

TIME: A - 7 n

DATE: 9ll 1/96

THIS FAX CONSISTS OF 5 PAGES (INCLUDING THIS PAGE)

VERIFICATION PHONE NUMBER: RECEIVING FAX NUMBER: NlR-7G7-3579

COMMENTS:

I received from Grant Hetherington information on emissions from leather tanning facilities in your state. Our company is developing an AP-42 Emission Factor section on leather tanning for the EPA and we need the actual test reports to develop emission factors. Mr. Hetherington gave me your name and Andy Seeber's name and suggested that either of you could tell me whether any actual testing was done and if there are any test reports with productionlprocess data that we could get. I would appreciate your help! Thanks,

Amy &&hall

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State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES PO Box 7921

101 South Websier Street Madlson, Wlsconsln 53707-7921

Tommy G. Thompson, Governor George E. Meyer, Secretary

TELEPHONE 608-286-2621 FAX 608-267-3579 TDD 608-267-6897

August 7, 1996 File Code: 4505

Amy Marshall Midwest Research Institute Suite 350 401 Harrison Oaks Blvd. Cary, NC 27513

SUBJECTS: 1994 AEI Emissions from Leather Tanning Processes.

Dear Ms. Marshall

I have enclosed the requested information fmm the 1994 Wisconsin Air Emission Inventory pertaining to sources a t facilities with leather tanning processes. I selected the processes using the following Source Classification Codes: 32099997,32099998 and 32099999. On the attached page, I have described the formats of the three electronic files on the enclosed diskette.

Also, I have included a bill for the cost of the data processing and materials needed to prepare your request. If you have any questions, please call me at 608/264-8854.

Sincerely,

Grant D. Hetherington, &#Quality Analyst Planing Section Bureau of Air Management

Quality Natural Resources Management Through Excellent Customer Service

The three files are in ASCII delimited format (Le. each field separated by a comma and character fields enclosed in quotation marks). Each electronic file are sorted by facility name (FID). Criteria pollutant emissions are in tondyear. Toxic pollutant emissions are in pounddyear. The fields in each record are in the following order from leR to right:

acility Name Facility Name Facility Name

lhcation Address lkource ID bource Id II hocation Citv IlSource Descriotion IlFuel Number II Ihailine Address IlFuel Number lbource Classification Code 11

SO, Emissions

NO, Emissions

ROG Emissions

'r Contact Phone PMlO Emissions kumber II

'r Contact Phone lkxtension 11 11 11

~ _ _ - - -~ t,- I

*MIDWEST RESEARCH INSTITUTE

401 Harrison Oaks Blvd. Cay, N.C. 27513 Telephone: (919) 677-0249 Fax: (919) 677-0065 Internet rnri45l@nando.net

I Suite 350

FAX TRANSMISSION

Mike Rudawski, PA Air Amy Marshall, ext.

TO: FROM: TIME: 11:21 AM DATE: August 6,1996

THIS FAX CONSISTS OF 3 PAGES (INCLUDING THIS PAGE)

VERIFICATION PHONE NUMBER: RECEIVING FAX NUMBER: 71 7-772-2303

COMMENTS:

Mike -- A few weeks ago you sent me a printout of your database on leather t h i n g companies. I would like to know if either Mercersburg Tanning or Garden State Tanning ever did emissions tests on PM from buffing operations. We need actual test data to be able to develop AP-42 emission factors, so we need a copy of the actual test report if any exist. The printouts from those two facilities had PM listed for buffing. I’ve included the pages in my fax. If you find there are test reports that we can get, please contact me at 919-677-0249, ext. 5135. Ifthere is a problem with confidentiality, we can go through the work assignment manager at EPA and use their CBI procedures. Look forward to hearing from you -- thanks for your help,

Amy Marshall MRI

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06/25/97 8:22AM Job 322 Page 1 1 2 ,

FAX COVER PAGE

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Fax:

From: Frank I I . l<utl; i l ld

~~ ......... . . . . . ~- ....... Fnx: 7 0 4 - L S L - X L 5 5

Phone: 704-252-X25-I ..... ......... .

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.............................. . . . . . . . . . . .............

............ -. ................... ........ .- . . . . . . . ___

~ ~ _ _ _ _ -

s,?nt PY: FRANK H. RUTLANO 7042528255 06 /25 /97 8:22AM Job 322 Page 212

AK I CA 3 FL I GA 1 u. 4 IN 1

38 Likeview Road Asheville. KC ZR8O-l

MD 1 NC 1 MA 14 OH I MI 3 OR 2 MN 3 PA 8 MO 3 T N 6 MT I TX 6

phone: 701-252-8254 fa*:: 7Q.-252-x255

niodern: 704-2524256 e-ni.iil: thrutldnd~~.~ol.i.onr

June 21. 1997

I A 2 INE 2 I UT 1 KY 4 I NH 2 I VA 1 KS 1 I NJ 4 I WI 14 ME 4 I NY 14 ]TOTAL 1 1 1

Please do not hesitate to contact me if I can be of further assistance

cc: Charlie Myers Nick Cory John Wittenborn 1 Frank Rutland

June 24. I997

Ms. Amy Marshall Midwest Research Institute Suite 350 401 Harrison Oaks Blvd. Cary. NC 27513

I was able to get to your request more quickly than 1 had expected. The following is a listing by state of the current number of leather tanning and finishing facilities (SIC 3 I 1 I ) . Please be advised this i s only an approximate list and is done to the best of my knowledge and ability. There are quite a number of these facilities, with which I am not personally familiar and am not even absolutely certain they are still in operation. Also, please understand these are not all complete (hide to leather) tanning facilities. Our industry has become very fragmented for commercial and environmental reasons, and there are very few complete tanneries remaining. Inclusion on this list. therefore, simply indicates the facility performs some part of the tanning finishing operation. Many, for example are only contract finishers and do nothing else. Despite these reservations, I believe this listing is reasonably accurate, and certainly sufficient for your intended use.

Please do not hesitate to contact me if I can be of hrther assistance.

cc: Charlie Myers Nick Price John Wittenborn Frank Rutland I